Justia U.S. 1st Circuit Court of Appeals Opinion Summaries

The First Circuit affirmed the decision of the district court dismissing Plaintiff’s action on the grounds that the lawsuit was, in essence, an appeal from a state-court judgment, and therefore, the court lacked jurisdiction to hear it under the Rooker-Feldman doctrine, holding that the district court correctly held that it lacked jurisdiction to hear Plaintiff’s claims.This appeal arose from Plaintiff’s legal challenge seeking to void two Massachusetts Superior Court conditions of probation imposed on the adult male who was convicted of statutory rape after impregnating Plaintiff when she was a minor. One of those conditions ordered the defendant to acknowledge paternity of the child. The district court decided that it did not have jurisdiction over the claims. The First Circuit affirmed, holding that because the relief Plaintiff sought was based on her claim that the Massachusetts Supreme Judicial Court erred in the adjudication of her case, the district court properly dismissed this case for want of jurisdiction. View "Tyler v. Supreme Judicial Court of Massachusetts" on Justia Law

A trial court that wishes to us the McDonnell Douglas framework, see McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802-804 (1973), as part of its jury instructions should translate it into everyday parlance and fit it to the facts and circumstances of a particular case.In this case alleging violations of federal and state law, including the Family and Medical Leave Act and the Rhode Island Civil Rights Act, the First Circuit affirmed the judgment of the district court entering a take-nothing verdict in favor of Defendants. Plaintiff moved for a new trial, arguing, among other things, that the district court erred in employing the McDonnell Douglas framework in its jury instructions. The First Circuit affirmed, holding that the district court’s jury instructions as a whole were satisfactory. View "Teixeira v. Town of Coventry" on Justia Law

David Efron and Madeleine Candelario were involved in a divorce proceeding and a pending marital property division proceeding before the superior court of Puerto Rico. In the divorce proceeding, the superior court ordered Efron, the sole owner of the Law Offices of David Efron, P.C. (the Efron Firm), to pay almost $5.5 million plus interest to Candelario. When Efron refused to pay, Candelario resorted to garnishing funds owned by Efron. In a separate case, the Efron Firm secured a settlement for its clients, and the defendants deposited the Efron Firm’s attorney’s fees in the federal district court registry. In the meantime, in the divorce proceeding, the court issued an order garnishing amounts owed to Efron. Candelario requested that the district court transfer the amounts deposited in the district court registry pursuant to the settlement in the separate case. The superior court granted the request. The First Circuit reversed, holding that funds in the federal court registries are protected under the doctrine of custodia legis from garnishment or attachment by a state court. Remanded. View "Law Offices of David Efron, PC v. Candelario" on Justia Law

A Massachusetts district court awarded damages to Dawn Irish arising out of her divorce from Craig Irish and the separation agreement filed in their divorce proceeding. Dawn later filed a complaint in federal district court based on diversity jurisdiction, alleging various contract, tort, and fraud claims against Craig for Craig’s alleged failure to fully disclose his assets or deal in good faith during the negotiation of the parties’ separation agreement. The federal court exercised jurisdiction over the claims, and Craig appealed. The First Circuit vacated the judgment, holding that the district court lacked subject matter jurisdiction pursuant to the domestic relations exception to federal diversity jurisdiction. Remanded for dismissal of the action, with prejudice as to federal jurisdiction and without prejudice as to the assertion of claim in an appropriate state court. View "Irish v. Irish" on Justia Law

Petitioners, a group of individuals and advocacy groups, filed a petition challenging the constitutionality of Article 68 of the Civil Code of Puerto Rico and other laws of the Commonwealth that prohibit same-sex couples from marrying. After the lower court dismissed Petitioners’ claims, the United States Supreme Court decided Obergefell v. Hodges. All parties subsequently agreed that the Commonwealth’s ban on same-sex marriage was unconstitutional. The First Circuit agreed and vacated the judgment. On remand, however, the district court did not enter judgment in favor of Petitioners but, instead, issued a memorandum concluding that the Commonwealth’s ban was not unconstitutional because the “right to same-sex marriage” had not been determined to apply in Puerto Rico. Petitioners requested a writ of mandamus requiring the district court to enter judgment in their favor striking down the ban as unconstitutional. Respondents moved for leave to join in Petitioners’ request. The First Circuit granted Petitioners’ petition for writ of mandamus and Respondents’ motion to join in the petition, holding that the district court erred in ruling that the ban is not unconstitutional and directly contradicted the First Circuit’s mandate and compounded its error by failing to enter a final judgment to enable an appeal in ordinary course. View "In re Conde-Vidal" on Justia Law

Petitioners, a group of individuals and advocacy groups, filed a petition challenging the constitutionality of Article 68 of the Civil Code of Puerto Rico and other laws of the Commonwealth that prohibit same-sex couples from marrying. After the lower court dismissed Petitioners’ claims, the United States Supreme Court decided Obergefell v. Hodges. All parties subsequently agreed that the Commonwealth’s ban on same-sex marriage was unconstitutional. The First Circuit agreed and vacated the judgment. On remand, however, the district court did not enter judgment in favor of Petitioners but, instead, issued a memorandum concluding that the Commonwealth’s ban was not unconstitutional because the “right to same-sex marriage” had not been determined to apply in Puerto Rico. Petitioners requested a writ of mandamus requiring the district court to enter judgment in their favor striking down the ban as unconstitutional. Respondents moved for leave to join in Petitioners’ request. The First Circuit granted Petitioners’ petition for writ of mandamus and Respondents’ motion to join in the petition, holding that the district court erred in ruling that the ban is not unconstitutional and directly contradicted the First Circuit’s mandate and compounded its error by failing to enter a final judgment to enable an appeal in ordinary course. View "In re Conde-Vidal" on Justia Law

This putative class action was brought on behalf of ten foster children in the custody of the Rhode Island Department of Children, Youth and Families (DCYF). The complaint alleged that DCYF’s failings exposed foster children in its custody to an unreasonable risk of harm and that the State had failed to comply in various respects with the Adoption Assistance and Child Welfare Act. After much skirmishing between the parties and delay during discovery, trial commenced. At that point, the claims of all but two of the named plaintiffs had been rendered moot through aging or adoption. The district court concluded (1) Plaintiffs had presented insufficient evidence to establish that DCYF’s policies and customs had either harmed them or exposed them to an unreasonable risk of harm, and (2) Plaintiffs failed to carry their burden of proof with respect to their statutory causes of action. Plaintiffs appealed, claiming myriad errors relating to pretrial proceedings. The First Circuit vacated the judgment, holding that the district court abused its discretion when it, in two case management orders, denied Plaintiffs’ counsel access to their own clients and prevented Plaintiffs from seeking plainly relevant discovery. View "Danny B. v. Raimondo" on Justia Law

Father was a citizen of Argentina. Mother was a U.S. citizen and permanent resident of Argentina. While living in Argentina, the parties had a child. After the parties separated, they reached a child custody agreement providing that the child would reside with Mother and Father would have visitation. In 2013, Mother left Argentina with the child and moved to Massachusetts. The relationship between the parties subsequently deteriorated, and in 2014, Father filed this action pursuant to the Hague Convention on the Civil Aspects of Child Abduction, as implemented by the International Child Abduction Remedies Act, to return the child to Argentina. The district court ordered the child’s return on the basis that the child’s habitual residence lay in Argentina because Father never fully agreed to allow the child to move to Massachusetts. The First Circuit reversed, holding (1) the United States was the child’s habitual residence at the time of his removal based on his parents’ mutual and settled agreement to move him there; and (2) Father did not meet his burden to establish a presumption of wrongful removal. View "Mendez v. May" on Justia Law

Defendants in this case were the Governor of Massachusetts, the Secretary of the Executive Office of Health and Human Services, and the Commissioner of the Massachusetts Department of Children and Families (DCF). Six children brought this class action in federal court on behalf of an estimated 8,500 children who are (or will be) committed to Massachusetts foster care custody as a result of their having suffered from abuse or neglect. Plaintiffs asserted that DCF so exposes the plaintiff class to harm or the risk of harm that it is unconstitutional and violates the Adoption Assistance and Child Welfare Act of 1980. Plaintiffs sought a broad injunction preventing Defendants from subjecting the plaintiff children to practices that violate their rights. The district court granted judgment for Defendants on all claims. The First Circuit affirmed, holding that Plaintiffs failed to demonstrate class-wide constitutional violations, nor a violation of the AACWA, and so injunctive relief was not warranted. View "Connor B. v. Patrick" on Justia Law

Mother and Father had two minor children. The family lived in Canada for approximately three and a half years before Mother relocated the children to the United States, where the entire family had never lived together. Father filed a petition in a federal district court for the return of his children to Canada pursuant to the Hague Convention on the Civil Aspects of International Child Abduction and its implementing statute, the International Child Abduction Remedies Act. A federal district court granted Father’s petition, concluding (1) Canada was the children’s country of habitual residence, and they were wrongfully removed for purposes of the Hague Convention; and (2) there was no grave risk that returning the children to Canada would expose them to physical or psychological harm. The First Circuit affirmed, holding that the district court did not err in (1) finding that Canada was the children’s country of habitual residence; and (2) concluding that returning the children to Canada would not involve a grave risk of physical or psychological harm. View "Mauvais v. Herisse" on Justia Law